`
`
`
`
`
`
`IPR2017-00255
`U.S. Patent No. 8,718,158
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`DISH NETWORK L.L.C.
`Petitioner
`
`v.
`
`TQ DELTA LLC
`Patent Owner
`
`
`
`Case IPR2017-00255
`Patent 8,718,158
`
`
`
`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 41.10(c)
`
`
`
`
`
`
`
`
`
`Atty Docket No. DISH-006/00US
`
`
`IPR2017-00255
`U.S. Patent No. 8,718,158
`
`Petitioner Dish Network L.L.C., respectfully requests that the Board
`
`
`
`
`recognize Stephen McBride, Esq., as counsel pro hac vice during this proceeding.
`
`I.
`
`BACKGROUND
`Petitioner’s Motion for Pro Hac Vice Admission is being filed in compliance
`
`with and pursuant to the “Order—Authorizing Motion for Pro Hac Vice
`
`Admission” in Case No. IPR2013-00639 (MPT) [“the Order”].
`
`II.
`
`STATEMENT OF FACTS
`
`As required by the Order, the following statement of facts shows that there is
`
`good cause for the Board to recognize Mr. McBride pro hac vice.
`
`Mr. McBride is an experienced litigation attorney and has been involved in
`
`numerous complex litigations in federal courts. Mr. McBride’s biography is
`
`attached hereto as Exhibit 1021 to this Motion.
`
`Mr. McBride has reviewed U.S. Patent No. 8,718,158, and the petition
`
`already filed in this proceeding. Further, Mr. McBride is familiar with the pending
`
`litigation between the parties pending before the United States District Court,
`
`District of Delaware, entitled TQ Delta LLC v. DISH Network Corporation, et al.,
`
`Case No. 1-15-cv-00614; and, as such, is familiar with the subject matter at issue
`
`in this proceeding.
`
`Therefore, Petitioner respectfully submits that there is good cause for the
`
`Board to recognize Mr. McBride as counsel pro hac vice during this proceeding.
`
`
`
`1
`
`
`
`Atty Docket No. DISH-006/00US
`
`
`
`
`
`IPR2017-00255
`U.S. Patent No. 8,718,158
`
`
`III. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`Petitioner’s Motion for Pro Hac Vice Admission is accompanied by a
`
`Declaration of Stephen McBride attached hereto as Exhibit 1022 as required by the
`
`Order.
`
`Dated: January 10, 2017
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: 650-843-5001
`Fax: 650-849-7400
`
`
`
`
`By:
`
`
`
`
`Respectfully submitted,
`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`Counsel for Petitioner
`
`
`
`2
`
`
`
`Atty Docket No. DISH-006/00US
`
`
`
`
`
`IPR2017-00255
`U.S. Patent No. 8,718,158
`
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of
`the attached PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`(Stephen McBride) and related documents, are being served via electronic mail on
`the 10th day of January, 2017, upon counsel of record for the Patent Owner as
`follows:
`
`Peter J. McAndrews
`pmcandrews@mcandrews-ip.com
`Thomas J. Wimbiscus
`twimbiscus@ mcandrews-ip.com
`Scott P. McBride
`smcbride@ mcandrews-ip.com
`Christopher M. Scharff
`cscharff@ mcandrews-ip.com
`
`
`
`Dated: January 10, 2017
`
`
`
`
`
`
`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`140278351 v1
`
`
`
`
`
`1